Prohibited use and restricted jurisdictions

Who this binds and why it is public

This policy applies to every client of Conexus Crypto, to anyone acting for a client, and to anyone attempting to use the desk without becoming a client. It forms part of our terms of business, and accepting a quote means accepting it.

It is published rather than kept internal for a simple reason: most of the transactions we decline could have been avoided if the person had known in advance that we do not do that. Reading this page is cheaper for both of us than discovering it after a crypto asset has already been sent.

Funds we will not accept

We will not buy, sell, convert, hold, transmit or in any way handle crypto assets or rand that are, or that we reasonably suspect to be:

• The proceeds of unlawful activities, as defined in the Prevention of Organised Crime Act 121 of 1998 — including fraud, theft, corruption, tax evasion, illicit trade and the proceeds of any offence, wherever committed.
• Derived from darknet marketplaces, whether directly or through intermediate addresses.
• Ransomware, extortion or fraud proceeds, including funds traceable to business email compromise, romance fraud, investment fraud and pig-butchering schemes.
• Mixer-derived — funds that have passed through a mixing or tumbling service, a coin-join used to break traceability, or a chain-hopping pattern whose evident purpose is to defeat attribution.
• Connected to a sanctioned person or entity, or to terrorist financing or proliferation financing. See sanctions and politically exposed persons.
• The subject of a preservation or restraint order, a court order, or an unresolved claim by a third party.

We use blockchain analytics on incoming and outgoing addresses. An attribution is not a verdict, and a direct or indirect exposure will usually produce a question before it produces a refusal — but where the exposure is direct and material, the answer is no, and the funds are not simply returned. What happens next is governed by the FIC Act, not by our preference.

No third-party deposits, no third-party payments

Both legs of a trade must be in the name of the client we have onboarded.

• Rand must arrive from, and settle to, a South African bank account in the client's own name. We do not accept payment from a friend, a spouse, an employer, a company you own but which is not the client, or an attorney's trust account operating for someone else.
• Crypto assets must be sent from a wallet the client controls, and are returned or delivered only to a wallet the client controls and which has been verified.
• We do not pay a third party out of your proceeds. The only structured exception is a conveyancing attorney's trust account against a signed agreement of sale, where the client is the purchaser named in that agreement, and it is handled under a specific process.

This is not a preference. A third-party payment breaks the audit trail that the FIC Act requires us to be able to reconstruct, and it is the single most common structure used to launder value through an otherwise legitimate desk. If the account name does not match the client, the transaction stops until it does.

Not a payment service, not a remittance service

Conexus operates an exchange service. We convert crypto assets to rand and rand to crypto assets for our own account, and we settle with the client. We are not a payment service provider, not a money remitter, and not a participant in the National Payment System.

Accordingly, the desk may not be used to:

• send value to another person, in South Africa or abroad, on your behalf;
• collect payments from your customers;
• settle invoices due by you to your suppliers, other than by paying you so that you can settle them yourself;
• hold a balance for you between transactions, or act as a wallet or a store of value;
• perform a series of transactions whose real purpose is transmission rather than exchange.

Joint Communication 1 of 2026, dated 28 May 2026, confirms that facilitating a customer's payment to a merchant in crypto assets — property expressly included — is an intermediary service under the FAIS Act, and separately confirms that a crypto asset is not money and not funds, so the transaction falls outside the National Payment System Act 78 of 1998. The consequence for you is that none of the protections of the payment system attach to a crypto leg: no reversal, no chargeback, no settlement finality rules to fall back on.

No structuring

Structuring means arranging transactions so as to avoid a reporting threshold, a due diligence trigger, or a monitoring rule. It is prohibited here in every form, including:

• splitting one transaction into several smaller ones to stay under a threshold;
• spreading a transaction across several days, several assets, several networks or several accounts for the same purpose;
• using family members, employees, colleagues or newly formed entities as fronts for what is economically one trade;
• timing transfers so that each one falls below the travel rule verification relief level of R5 000.

Two things are worth saying plainly. First, our monitoring aggregates linked transactions, so structuring generally does not work. Second, an attempt to structure is itself a red flag, and a section 29 report may follow — which we would not be permitted to tell you about. If a trade is large, quote it as a large trade. Size is not a problem at this desk; disguising size is.

Exchange control: no externalisation of capital

This is the prohibition that gets South Africans into the most trouble, and it is the one most often misrepresented by other operators.

The South African Reserve Bank's Financial Surveillance Department has stated the position clearly. A crypto asset is not legal tender. FinSurv will not approve a cross-border transfer for the purpose of purchasing crypto assets. Buying a crypto asset in South Africa in order to move capital out of the country contravenes the Exchange Control Regulations and is a criminal offence. Value cannot be brought back into South Africa through a crypto asset under the allowances either.

So the desk may not be used to externalise capital, to circumvent the single discretionary allowance or the foreign capital allowance, or to structure around either. The single discretionary allowance is R2 million per calendar year, raised from R1 million by Exchange Control Circular 6/2026 of 8 April 2026, and the foreign capital allowance is R10 million, requiring a SARS Tax Compliance Status PIN. Both are used through your own bank as an authorised dealer. Neither runs through us, and neither becomes a crypto allowance by being larger.

The draft Crypto Assets Manual for cross-border activities published by the SARB and National Treasury on 3 August 2026, open for comment until 30 September 2026, may change how this works in future. It is a draft. We do not apply it as law and we will not let anyone rely on it as though it were.

If your intention is to move money offshore, use your bank and your allowances. If someone offers to do it for you through crypto, they are offering to commit an offence with your money.

Other prohibited conduct

The desk may also not be used to:

• trade on behalf of an undisclosed principal, or to conceal who the real party to a transaction is;
• provide false, altered or borrowed identity or address documents, or a false account of the source of funds;
• facilitate tax evasion, or to create documents that misstate the nature, date or value of a transaction;
• settle unlawful gambling, unregistered lending, or any activity requiring a South African licence the client does not hold;
• fund the acquisition or distribution of illegal goods or services;
• run a bureau or sub-desk — reselling our quotes to your own clients as though you were the counterparty;
• abuse the quoting process, including systematically accepting quotes and failing to settle;
• threaten, harass or attempt to induce our staff to depart from these rules.

What we do about it

We reserve the right, at any point and without prior notice, to:

• decline a quote request, an instruction or a transaction, with or without giving reasons;
• delay a transaction while due diligence, screening or a travel rule enquiry is completed;
• reverse a transaction where it can lawfully be reversed and where it should not have been executed;
• freeze property where the law requires it to be frozen;
• terminate the relationship;
• report to the Financial Intelligence Centre, the FSCA, the South African Police Service or another competent authority, without notifying you, where the law requires or permits it.

Where funds can lawfully be returned, they are returned to their verified source — the same bank account, or the same wallet — never to a different destination, and net of the network or banking cost of the return. The detail sits under cancellation, reversal and refunds.

Where we decline, we may be legally prohibited from telling you why, and a non-answer should not be read as an accusation or as rudeness.

If you are worried about your own funds

People sometimes discover that money they received honestly has a history they knew nothing about — an inheritance routed strangely, a client payment from an account that turns out to be compromised, an asset bought years ago on a platform that no longer exists. Say so before you send anything. A trader can tell you whether the desk can work with it, and what would be needed. Disclosing an awkward fact at the start is treated as what it is: cooperation.

Attempting to conceal the same fact is a different matter entirely, and it is the point at which a routine trade becomes a reportable one.

To raise a concern about the desk itself, or about someone claiming to represent it, check the verified channels page first, then write to support@conexus-crypto.com.